To cultivate, as, land. "Improved land" is such as has been reclaimed, is used for purposes of husbandry, and is cultivated as such, whether the appropriation is for tillage, meadow or pasture. Improvement. 1. Amelioration in the condition of property by the outlay of labor or money. Includes repairs or additions to buildings, the erection of fences, the annexation of fixtures, etc. See BETTERMENT; ESTOPPEL. As used in a will, relative to property, construed according to the subject-matter. A gift of the improvement of land may constitute a freehold estate, for the devisee's life; of plate, pictures, furniture, it would be the possession and use; of money, securities, or stocks, it would be the income.8 Bedding oysters is not an "improvement," within the meaning of a statute authorizing riparian owners to make improvements on navigable streams. The mere depositing of the oysters in the water implies no essential union or relation between the main land and the soil under the water contiguous; and there1 [Pike v. Hanson, 9 N. H. 493 (1838); Smith v. State, 7 Humph. 43 (1846). See also 35 Ind. 15, 286; 43 id. 65; Baldw. 600; 12 Ark. 43; 133 Mass. 399; 81 N. C. 528; 9 Johns. 117; 5 Vt. 588; 1 Bish. Cr. L. § 553. 23 Bl. Com. 127, 138; 4 id. 218; Castro v. De Uriarte, 12 F. R. 253 (1882). • Wood v. Graves, 144 Mass. 367-68 (1887), cases. R. S. § 990; The Blanche Page, 16 Blatch. 8 (1879). 1 McMaster, Hist. Peop. U. S. 98 (1883). • [Clark v. Phelps, 4 Cow. 203 (1825). See also 40 Cal. 33; 8 Allen, 213; 68 Pa. 396. 7 See Schenley's Appeal, 70 Pa. 102 (1871); Schmidt v. Armstrong, 72 id. 356 (1872); French v. Mayor of New York, 16 How. Pr. 222 (1858); 32 Iowa, 254; 34 id. 559; 1 Cush. 93; 22 Barb. 260; 78 N. Y. 1, 581; 18 N. J. L. 424. • Lamb v. Lamb, 11 Pick. *375 (1831), Shaw, C. J. fore does not effect an improvement of the land implied in something created or constructed, attached to the shore.1 Works within Internal improvements. the State, by which the public are supposed to be benefited; such as the improvement of highways and channels of travel and commerce.2 See AID, 1, Municipal. Under improvement. Used, occupied, employed, turned to profitable account.3 2. An addition of some useful thing to a patentable object. See further INVENTION; PATENT, 2; PROCESS, 3.